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patient safety events.^125 New Jersey sought to create a similar
patient safety regime.
B. The New Jersey Patient Safety ActThe New Jersey Patient Safety Act was, in part, a response
to revelations that a New Jersey nurse named Charles Cullen
had administered lethal doses of medication to over forty
patients under his care over a several-year period at roughly a
dozen different facilities.^126 The PSA’s drafters believed that a
more robust centralized reporting system could have sooner
uncovered Mr. Cullen’s crimes.^127
The portion of the Act entitled “Findings, declarations
relative to patient safety” accurately summed up some basic
tenets of the patient safety movement.^128 Readers should take
(^125) The Patient Safety and Quality Improvement Act of 2005, AGENCY
FOR HEALTHCARE RESEARCH & QUALITY (June 2008), http://www.ahrq.gov/
qual/psoact.htm. The agency specifically cites the Institute of Medicine
Report as the impetus for the bill.
(^126) Senator Joseph F. Vitale, Chairman of the Senate Health and Human
Services and Senior Citizens Committee, remarked during committee hearings
that “this [bill] is, in part, due to the recent revelations of Charles Cullen,
who has professed to have killed at least 40 individuals under his care.”
Testimony on the Patient Safety Act: Hearing on S.B. 557 Before the S.
Comm. on Health, Human Servs. & Senior Citizens, 211th Leg., 2004–2005
Sess., at 2 (N.J. 2004) [hereinafter Senate Hearing]. In 2006, Cullen pleaded
guilty to twenty-nine counts of murder and six counts of attempted murder in
New Jersey and Pennsylvania courts. Sophie Sohn & Allan Chernoff, Killer
Nurse Gets 11 Life Sentences, CNN JUSTICE (Mar. 10, 2006, 11:11 AM),
http://articles.cnn.com/2006-03-02/justice/killer.nurse_1_cullen-names-killer-
nurse-john-shanagher?_s=PM:LAW.
(^127) See Senate Hearing, supra note 126, at 31 (testimony of U.S. Senator
Frank Lautenberg’s Office) (commending the committee “for convening this
important hearing to discuss recommendations to improve the integrity and
safety of our health-care system in the wake of the tragic murders carried out
by Charles Cullen”); id. at 41 (testimony of David Knowlton, Chairman,
New Jersey Health Care Quality Institute) (“[I]n the Cullen case, there were
people who had concerns, but they—if they’re a nurse, they [first] have to
report it to a supervisor.... [T]he new bill that you’ve just approved...
would provide immunity.”).
(^128) N.J. STAT. ANN. § 26:2H-12.24 (West 2007 & Supp. 2012).